The assessee, a contractor, had sold immovable property in AY 2015–16 but did not file a return. Based on information from the Sub-Registrar, the AO issued a notice u/s 148A(b) on 24-03-2022, passed an order u/s 148A(d) on 18-04-2022, and issued a notice u/s 148 on the same date, completing reassessment with additions of ₹1.77 crore. The assessee contended that, as per the first proviso to s. 149(1)(b) and relying on Hexaware Technologies Ltd. v. ACIT   [2024] 162 taxmann.com 225 /464 ITR 430  (Bom.)( HC ) and UOI v. Rajiv Bansal [2024] 167 taxmann.com 70 /340 CTR  865  (SC)  the six-year limit under the old regime expired on 31-03-2022, hence the notice dated 18-04-2022 was time-barred. The Tribunal held that the first proviso restricted reopening for years prior to AY 2021–22 where the six-year limit had expired, and that the fifth proviso (exclusion of time allowed to respond to SCN) could not extend the bar under the first proviso. Since the notice was issued after 31-03-2022, it was invalid; the reassessment and additions were quashed.(AY. AY. 2015–16) )(ITA No. 926/Mum/2025, dt. 28-04-2025 )